Deloitte Tax LLP – $96,262.00/Year

Masters or higher degree in Accounting, Finance, Taxation, Business Administration or related field willing to accept foreign education equivalent plus three years of experience in performing tax structuring, tax supply chain planning, and acquisition financing for multinational corporations, partnerships or private equity funds. Experience must include two years of auditing income tax provisions and disclosures under ASC 740 and analyzing deferred tax on outside basis differences of foreign investment; analyzing, quantifying, and implementing tax reform TCJA legislation impacts on both tax compliance and planning projects for corporations, partnerships, taxexempt entities, and ICDISCs; performing foreign tax credit analysis, including reviewing Section 901 credits calculations, Section 78 grossup calculation, and the analysis of complex foreign tax returns; assessing international tax compliance, including the preparation of Forms 1120F, 5471, 5472, 8865, 8858, and 1118, earnings profits EP analysis, Subpart F incomehovering deficits calculations, withholding tax application analysis, and related disclosures and statements; researching and analyzing complex tax rules and regulations of foreign jurisdictions and U.S. relating to structuring investments; researching and writing memoranda on U.S. federal income tax issues relating to the investment of earning in U.S. property under Section 956, treatment of foreign currency transactions under Section 988, income sourcing analysis under Section 861 Section 862, related party transactions under Section 304, and U.S. tax implications on foreign income, including computer software transactions and Permanent Establishment matters; providing international tax planning for outbound and inbound multinational companies to minimize global effective tax rate and satisfy business needs, including financing structuring, cash repatriation modeling, CFC planning, foreign exchange planning, and loss utilization modeling; assisting taxexempt clients, including foundations and public charities, with their compliance with international tax filing requirements in the U.S.; preparing and reviewing returns for interest charge domestic international sales corporations ICDISCs, and entities created to promote export sales of U.S. companies; and mentoring and coaching junior team members. Position requires approximately 10 domestic travel.br From H. 10B Tax Manager or related occupation requiring experience performing tax structuring, tax supply chain planning, and acquisition financing for multinational corporations, partnerships or private equity funds.